Types of cryptocurrency registration
- Cryptocurrency exchange operator (when the company exchanges cryptocurrency owned by the third parties and earns commission)
- Cryptocurrency depository wallet operator (when the company manages or stores digital assets of clients – f.e BTC, ETH)
Requirement for crypto company in Lithuania:
Company registration in Lithuania is mandatory and its activity shall be separated from the licensed traditional finance activity (f.e payment institution, payment service provider) – a separate legal entity
Preparation of needed policies for the provision of virtual currency activities
Drafting and implementation of AML/KYC control measures (AML policy, KYC policy, Risk Assessment)
- Members of the Management Board (Directors) as well as Ultimate Beneficial Owners (UBOs) of the Crypto company shall to meet the requirements of irreproachable reputation, that means:
- They cannot be sentenced for infringements related to private ownership, economic and business order, financial system, civil service or any public interest.
- Shareholders/Ultimate Beneficial Owner need to pass the Investors Assessment Commission (IAC).
- Approval of the Commission is required for all the investors (shareholders) planning investments into the Lithuanian financial sector.
- Cryptocurrency license holders are supervised by Financial Crime Investigation Service (FIS).
A company that has issued a cryptocurrency license from Lithuania needs to follow general requirements:
- Identify and verify customers upon starting a relationship or when the operation exceeds a certain amount
- Report to Financial Crime Investigation Service (FIS)
- Keep records up to date and data of clients based on requirements
- Appoint AML Officer
- Appoint Local MLRO, who shall be fully experienced in AML and should be Lithuanian residents – we can provide this service on request.
- Implement internal control policies and procedures based on requirements ( on request )
- Cryptocurrency company needs to be separated from licensed financial institution (EMI or any other).
Our offer for crypto companies:
- Arrangement of the documents for IAC
- Drafting of the company incorporation documentation meets legal requirements set to Virtual Currency Operators and limited liability company registration
- Preparation of the AML Policy, KYC Policy based on FCIS requirements (Risk Assessment on request), Adaptation of existing AML policies